News & Analysis as of

Books & Records FCPA Guidance

The Volkov Law Group

Revised FCPA Guidance: Effective Compliance Program and Internal Controls (Part V of V)

The Volkov Law Group on

The initial FCPA Guidance included valuable compliance program guidance keyed to the heading, “Hallmarks of an Effective Compliance Program.”  Issued in 2012, the outline of an effective compliance program was an important...more

Thomas Fox - Compliance Evangelist

The FCPA Resources Guide, Second Edition – the Accounting Provisions

The next area I want to explore in the RESOURCE GUIDE TO THE U.S. FOREIGN CORRUPT PRACTICES ACT, SECOND EDITION is around the information found in the chapter on Accounting Provisions, including both books and records and...more

Foodman CPAs & Advisors

Instituciones Financieras y el FCPA

La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios.  Exige que las empresas cuyos valores se...more

Foodman CPAs & Advisors

Financial Institutions and the FCPA

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It requires companies whose securities are listed in the US to maintain books and...more

Thomas Fox - Compliance Evangelist

The Problems with Facilitation Payments

The original version of the FCPA, enacted in 1977, contained an exception for payments made to non-U.S. officials who performed duties that were “essentially ministerial or clerical”. In 1988 Congress responded by amending...more

Thomas Fox - Compliance Evangelist

The Dutch Tulip Bubble and Internal Controls for Third Parties

Internal controls are a key tool to operationalize your third-party risk management program. The basic internal controls, that should be a part of any financial controls system. There were four significant controls the...more

Troutman Pepper

Enhanced Anti-Corruption Scrutiny in Construction Industry

Troutman Pepper on

Bribery and corruption have long plagued the construction industry, particularly in emerging markets in Latin America, Eastern Europe, the Middle East and Asia-Pacific. ...more

Thomas Fox - Compliance Evangelist

Evolution of Your Compliance Program

One of the most consistent themes from the Department of Justice (DOJ) regarding Foreign Corrupt Practices Act (FCPA) compliance programs has been continuous evolution. As far back as 2009, I heard Lanny Breuer say that your...more

Thomas Fox - Compliance Evangelist

Operationalizing Compliance: Part V – Controller’s Office

This week I have engaged in a series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I have been...more

The Volkov Law Group

The FCPA Guidance And Accounting Controls

The Volkov Law Group on

When Judge Sporkin, the father of the FCPA, assisted Senator William Proxmire in the drafting of the FCPA, he advised Senator Proxmire that a “books and records” provision was all that was needed to address the problem of...more

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